James H. Knowles and Gretchen R. Knowles v. Commissioner of Internal Revenue

Third Circuit

James H. Knowles and Gretchen R. Knowles v. Commissioner of Internal Revenue

355 F.2d 931, 17 A.F.T.R.2d (RIA) 358

Court of Appeals for the Third Circuit·Decided February 16, 1966·No. 15543_1·Published·Cited by 1 cases

Opinion

PER CURIAM.

There is substantial evidence on the whole case which supports the Tax Court findings of a value of at least $285 a share on September 23, 1954 for the CHD stock involved and that said stock was transferred to petitioner, James H. Knowles, as compensation for services. We are satisfied that the Tax Court did not err with respect to the Commissioner’s burden of proof and in holding that the deficiency asserted against the petitioners for the year 1954 is not barred by the statute of limitations on assessment.

The decision of the Tax Court will be affirmed.

Free access — add to your briefcase to read the full text and ask questions with AI

PER CURIAM.

There is substantial evidence on the whole case which supports the Tax Court findings of a value of at least $285 a share on September 23, 1954 for the CHD stock involved and that said stock was transferred to petitioner, James H. Knowles, as compensation for services. We are satisfied that the Tax Court did not err with respect to the Commissioner’s burden of proof and in holding that the deficiency asserted against the petitioners for the year 1954 is not barred by the statute of limitations on assessment.

The decision of the Tax Court will be affirmed.

James H. Knowles and Gretchen R. Knowles v. Commissioner of Internal Revenue, 355 F.2d 931, 17 A.F.T.R.2d (RIA) 358 (3d Cir. 1966).

Pincite

355 F.2d 931 (James H. Knowles and Gretchen R. Knowles v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

Related